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  • Comment Detail

  • Date: 03/17/16
    First Name: Steve
    Last Name: Baden
    Organization: RESNET
    City: N/A
    State: N/A
    Attachment: N/A
    Number: RIN-2590-AA27

  • Comment

    RESNET is a non-profit organization that sets the national standards for the inspection, testing and labeling of a home's energy performance. To date over 1.7 homes in the U.S. have been HERS rated and issued a HERS index Score. In 2015 over 38% of all new homes sold were HERS rated.

    RESNET wishes to commend the Federal Housing Finance Agency for the major steps it is taking in recognizing that energy bills is a major cost of housing and that energy efficiency can make homes more affordable..

    The following is RESNET's specific comments:

    Question 51. Should Enterprise support for multifamily properties that include energy improvements
    resulting in a reduction in the tenant’s energy and water consumption and utility costs be a
    Regulatory Activity? - Multifamily properties that includes energy improvements should be a
    Regulatory Activity.

    Question 59. Should Enterprise support for single-family properties that include energy
    improvements resulting in a reduction in the homeowner’s or tenant’s energy and water consumption
    and utility costs be a Regulatory Activity? - Energy improvements in single-family properties should be a
    Regulatory Activity. The lower risks of loan default and prepay.

    Question 53. Should the Enterprises require the lender to verify before the closing of an energyimprovement
    loan that there are reliable and verifiable projections or expectations that the proposed
    energy improvements will likely reduce the tenant’s energy and water consumption and utility costs
    and, if so, what standards of reliability, verifiability and likelihood of reduced consumption and costs
    should be required? - An energy assessment should be conducted before closing any energy-improvement loan.
    Assessments meet a baseline certification standard. A starting place would the RESNET Mortgage Industry National Home Energy Rating Standards - www.resnet.us

    Question 56. For the proposed requirement that the reduced utility costs will offset the upfront costs
    of the improvements within a reasonable time period, should a reasonable time period be defined
    and, if so, how? - The test of cost effectiveness should be based on a present value calculation that demonstrates that the added cost for financing the improvements must be lower than the projected energy savings. This approach is used by the FHA Energy Efficient Mortgage.